SCOTUSblog: Sprint Communications Company v. Jacobs
Discussion: The Iowa Utilities Board (IUB) ordered Sprint to pay intrastate access charges to Windstream, an Iowa communications company, for Voice over Internet Protocol (VoIP) calls. Sprint filed a complaint in federal district court seeking declaratory and injunctive relief. The same day, Sprint also filed a petition for review in Iowa state court, asserting that the IUB's order was preempted under federal law. The federal district court abstained pursuant to Younger v. Harris, 401 U.S. 37 (1971). In Younger, the Supreme Court held that federal courts were required to abstain from hearing any civil rights tort claims brought by a person who is currently being prosecuted for a matter arising from that claim ("Younger abstention"). Sprint argued that the proceedings were remedial, not coercive, and therefore Younger should not apply. Nonetheless, the District Court abstained and dismissed the action. The Eighth Circuit affirmed.
Issue: The question before the Court is whether the Eighth Circuit erred by concluding that Younger abstention is warranted not only when there is a related state proceeding that is “coercive” but also when there is a related state proceeding that is, instead, “remedial.”
Holding: In a unanimous decision, the Supreme Court ruled that this case did not fall within any of the three classes of exceptional cases for which Younger abstention is appropriate. As a result, the lower federal court cannot abstain and must consider the merits of Sprint's preemption complaint.